Privacy Policy

1. Our Company Information

Legal Business Name: Science Innovation Limited trading as Smartprepo Academy.

Registration entr

Contact for Privacy Inquiries:

Email: info@smartrepo.co.tz

2. Scope and Purpose

Smartprepo is an online SaaS tool and mobile app designed primarily for parents, guardians, students, and teachers to study and practice for tests and examinations. This Privacy Policy explains how we process personal data in accordance with applicable data protection laws.

3. Information We Collect

3.1 Personal Data

Note: We do not collect physical addresses unless you opt for a bank payment service; such address data is collected and processed by our third-party payment provider, Selcom Pay, and is not retained by Smartprepo.

3.2 How Data Is Collected

• User Input: Information provided through registration forms, contact forms, surveys, and other interactive elements.
• Social Login: We offer sign-in options through Google and Apple. When you use these services, we receive basic profile information from your social account as permitted by their privacy settings.
• Cookies: We use first-party cookies to enable core functionality (e.g., logging into your account) and for analytics. Tools like Google Analytics help us improve our Service. You can opt out of non-essential cookies via our cookie banner.

4. How We Use Your Information

We process your personal data only for purposes that are necessary and lawful, including to:

• Provide and maintain our Service;
• Personalize and improve your experience;
• Deliver customer support;
• Analyze usage and performance (via tools such as Google Analytics and Intercom).

Our legal basis for processing includes the performance of our contract with you, your consent where applicable, and our legitimate interests under applicable laws.

5. Data Sharing and Third-Party Transfers

We share your personal data only with trusted third parties, including:

• Google Analytics: For analyzing user interactions and improving our Service.
• Onesignal: For notification.
• Google Gemini API: For generating an AI tutor response when a student chooses to use the marking-scheme tutor.

5.1 AI Tutor Data Processing

When the marking-scheme tutor is used, we send Google Gemini only the selected question and options, the student's answer, the marking-scheme answer and explanation, education level and class, subject and topic, score, response language, and the messages in that tutor conversation. We do not intentionally send the student's or guardian's name, contact details, school details, account identifiers, or unrelated assessment records. Users must not enter personal or sensitive information in tutor questions.

Smartprepo stores tutor conversations for up to 30 days so they can be restored during review. Our Gemini API project has active Cloud Billing and is therefore treated as a Paid Service for data-use purposes; under Google's Gemini API terms, prompts and responses submitted through Paid Services are not used to improve Google products. Google may retain them for a limited period for abuse monitoring and legal or regulatory requirements. Google's terms and data-processing commitments govern Google's handling of that data.

These third parties are contractually obligated to protect your data in compliance with applicable data protection laws. Data transfers occur only to countries that provide an adequate level of protection as required by applicable regulations.

6. Cookies and Tracking Technologies

• Essential Cookies: Used to provide core functionality (e.g., authentication, session management).
• Analytics Cookies: Help us understand how our Service is used so we can improve it.

You may opt out of these cookies by adjusting your cookie preferences via our cookie banner. For further information on managing your cookie settings, please refer to our Cookie Notice.

7. Data Retention and Security

7.1 Data Retention

We retain your personal data for as long as your account remains active and for the duration necessary to provide you with our Service. Your personal data will not be deleted automatically due to inactivity; instead, it will only be removed upon your explicit request to delete your account.

Upon receiving a deletion request, we will initiate the process to remove your personal data from our active systems within a reasonable period (typically within 30 days). However, certain information may be retained for a limited period to comply with legal, regulatory, or contractual obligations (e.g., for record-keeping or tax purposes).

Additionally, we delete backups after a period of 30 days.

7.2 Security Measures

We implement strict security measures to protect your data, including:

• Access Controls: Only authorized developers and personnel have access to user data.
• Encryption: Sensitive information (e.g., passwords) is encrypted at rest.
• Regular Security Reviews: We continually assess and update our security practices to ensure ongoing protection.

8. Your Rights and Choices

Under applicable data protection laws, you have the following rights regarding your personal data:

• Access: Request a copy of your personal data.
• Correction: Request correction of any inaccurate or incomplete information.
• Deletion: Request deletion of your personal data, subject to legal obligations.
• Data Portability: Request your data in a structured, commonly used, machine-readable format.
• Objection and Restriction: Object to or request restrictions on our processing of your data.
• Withdrawal of Consent: Withdraw consent for processing, where applicable, without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at info@smartrepo.co.tz or use the designated channels in your account settings.

9. International Data Transfers

Your personal data may be transferred to and processed in third countries (example data servers). In all such cases, we ensure that appropriate safeguards are in place to maintain a level of protection equivalent.

10. Policy Updates

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and the updated policy will be effective immediately upon posting. Please check this page periodically for updates. Your continued use of our Service after any changes constitutes your acceptance of the revised Privacy Policy.

11. Children's Privacy

Our Service is intended for users who are at least 6 years old. The minimum age of consent varies by jurisdiction: Users of age between 6 and 17 must use Site under parent, guardian, teachers, or any adult over 18 years. Registration can only be done by an adult.